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Business profits – Reimbursement of expenses : Where Tribunal deleted disallowance made by Assessing Officer made disallowance under section 40(a)(i) treating expenses reimbursed by assessee to its non-resident AE as FTS under section 9(1)(vii) on account of non-deduction of tax under section 195, since Pr. Commissioner had failed to establish that said remitted fee would fall within ambit of any technical, managerial or consultative service that had been rendered, there was no substantial question of law arising for consideration – Principal Commissioner of Income-tax v. JAS Forwarding (P.) Ltd. – [2024] 162 277 (Delhi)



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